AMLify Adds Automated Periodic Review Reminders for TCSPs

AMLify has added automated periodic review reminders for trust and company service providers (TCSPs), so a nominee arrangement or beneficial ownership record due for reassessment surfaces automatically instead of relying on someone remembering to check.

What does the new periodic review reminder feature do?

Every nominee arrangement and beneficial ownership mapping created in AMLify's TCSP module can now carry a scheduled review date, set when the record is first documented. When that date arrives, AMLify flags the record on the AMLCO's dashboard and emails a notification. The reminder stays open until the AMLCO completes the review and records an updated decision.

Why do TCSPs need periodic reviews of nominee arrangements and beneficial ownership records?

Nominee director and shareholder arrangements, along with layered beneficial ownership structures, are the TCSP sector's defining risk under the AML/CTF Act 2006. A rationale that was reasonable at onboarding can go stale as a client's structure or jurisdiction exposure changes. Now that Tranche 2 has been in force for a month, AUSTRAC's early reviews are checking whether TCSPs can show ongoing oversight — not just a one-off assessment filed at onboarding and never revisited.

How does the reminder feature work in practice?

The workflow runs in three steps: 1. Set a review interval — the AMLCO chooses a review cadence for each record, based on the risk rating in the client's CDD file 2. Automatic flagging — AMLify surfaces the record on the compliance dashboard and emails the AMLCO once the interval elapses 3. Reassessment and sign-off — the AMLCO confirms whether the arrangement still holds, updates the file if needed, and AMLify timestamps the new decision

What happens if a scheduled review is missed?

A missed reminder doesn't disappear — it stays flagged as overdue until actioned, so a backlog is visible rather than buried. AUSTRAC's supervisory approach for TCSPs treats an undocumented or lapsed periodic review the same as never having done one at all. See the full TCSP compliance workflow on the AMLify TCSP industry page.

Key Takeaways

• Periodic review reminders are now built into AMLify's TCSP module — no more relying on memory to reassess nominee arrangements and beneficial ownership records
• Reminders surface on the compliance dashboard and by email once a set review interval elapses
• Overdue reviews stay visibly flagged until the AMLCO completes and signs off the reassessment
• This closes a common audit gap — AUSTRAC's post-1 July 2026 reviews are checking for ongoing oversight, not just onboarding-stage documentation
• Existing TCSP clients can set review intervals retroactively on records created before the feature launched

Frequently Asked Questions

Q: Which records can have a periodic review reminder in AMLify?

Any nominee arrangement or beneficial ownership mapping created in AMLify's TCSP module can have a review interval set. The AMLCO chooses the cadence when the record is first documented, or adds one retroactively to an existing record.

Q: How often should a TCSP review a nominee arrangement?

There's no fixed AUSTRAC-mandated interval — the appropriate cadence depends on the risk rating in the client's CDD file, with higher-risk arrangements reviewed more frequently. Many TCSPs using AMLify set a 12-month default and shorten it for higher-risk configurations.

Q: Does completing a review reset the reminder?

Yes. Once the AMLCO reassesses the record and signs off, AMLify timestamps the decision and schedules the next reminder based on the same interval, so the cycle continues automatically.

Q: Is this feature included in every AMLify plan for TCSPs?

Yes, periodic review reminders are included in AMLify's TCSP module across all plans, including the 14-day free trial. See /pricing for plan details.

This is general information only and not a substitute for legal advice.

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